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Planning
Innovative Local Government Plans
and Policies to Build Healthy Food Systems in the United States
Kailee Neuner, Sylvia Kelly and Samina Raja
Food Systems Planning and Healthy Communities Lab
University at Buffalo, The State University of New York
A growing number of local governments across the United States are rebuilding food systems 1 through innovative public policy. innovative public policy.
Local governments are using plans, Local governments are using plans, regulatory tools, fi scal incentives, and regulatory tools, fi scal incentives, and institutional mechanisms
institutional mechanisms to strengthen food systems. These public policy tools are being developed and implemented by different levels of local governments, including cities, counties, and regional governments.
This policy brief includes a synthesis of a synthesis of recent best practices of local government recent best practices of local government policy and planning
policy and planning designed to strengthen community food systems.
1 A food system refers to the network of activities, actors, resources, regulations, and institutions required to produce, process, distribute, and dispose food.
September 2011 2011
Offi cial plans adopted by local governments guide future public investments and shape development patterns in a community. Offi cial plans have a profound and lasting infl uence on the health of communities’ food systems and on residents’ ability to access healthful and affordable foods. Recognizing this infl uence, many local governments seek to strengthen their community’s food systems through offi cial plans.
Local governments incorporate food in offi cial plans using a variety of strategies. Some include food as an element, or, sub-element, within their comprehensive plans along with more traditional plan elements such as land use, housing, and transportation.
Food also appears as an element within sustainability or environmental plans. A small, but growing, number of governments are adopting stand-alone food systems plans, while others are adopting plans for a particular component of the food system such as urban agriculture.2 1
FOOD AS AN ‘ELEMENT’ IN OFFICIAL PLANS FOOD AS AN ‘ELEMENT’ IN OFFICIAL PLANS Comprehensive Plans
A number of comprehensive plans adopted by local and regional governments include strategies for improving the food system. Within comprehensive plans, references to the food system commonly appear in sections devoted to natural and agricultural resources, environmental stewardship, or energy (e.g. Boise, ID; Dillingham, AK; Dane County, WI;
Madison, WI; Marin County, CA; New Orleans, LA;
Southern California Association of Governments, CA). Some comprehensive plans mention food within sections devoted to health (e.g. Boston Metro Region;
Harrison County, MS). Still others interweave aspects of the food system throughout the comprehensive plan (e.g. Seattle, WA).
Below we review adopted comprehensive plans from around the country that aim to strengthen their community’s food system. The plans reviewed in this section are organized by levels of government (city and county), and more recent plans appear fi rst.
2 See the American Planning Association’s Planning Ad- visory Service Report Number 563 for a detailed analysis of plans that support urban agriculture. 1. Hodgson, K., M.C. Campbell, and M. Bailkey, Urban Agriculture: Growing Healthy, Sustainable Places, in Planning Advisory Service. January 2011, American Planning Association. p. 145.
PLANS PLANS
City-scale comprehensive plans
The ‘City of Dillingham Comprehensive Plan Update and Waterfront Plan’ (Alaska), adopted by the City Council on March 3, 2011, recognizes the role of the food system in meeting its energy goal to
“reduce resilience on costly imported goods; increase production and reliance on local resources.” The plan’s section on energy outlines an objective to “develop interest in the community to grow and gather food locally.” Strategies include education programs about the benefi ts of growing food locally, information about harvesting, caring, and preparation techniques, exploring “the feasibility of developing a passively heated commercial greenhouse to grow food,” and supporting and expanding an existing farmers’ market.
The plan outlines a timeframe for implementing each strategy and identifi es the entity primarily responsible for implementation. [2]
The ‘New Orleans 2030: Plan for the 21st Century’ (Louisiana), adopted by the City Planning Commission in 2010, addresses food in a subsection on “Urban Agriculture, Gardening, and Open Space.”
The primary goal of this section is to provide “ample opportunities for all residents to participate in and benefit from urban agriculture and community gardening.” The plan proposes to achieve this by
“support[ing] and promot[ing] urban agriculture and community gardening on public and private property.”
Suggested actions include removing zoning and regulatory barriers to both urban agriculture and farmers’ markets, performing an inventory of possible gardening sites, establishing a schoolyard greening program, and providing incentives to encourage reuse of vacant properties for urban agriculture. [3]
The 2006 ‘City of Madison Comprehensive Plan’ (Wisconsin) addresses food in its “Natural and Agricultural Resources” and “Economic Development”
sections. The plan outlines goals, objectives, and policies to protect the city’s food-related resources including farmland and community gardens. Goals discussed in the plan include “maintain[ing] existing agricultural operations in the City and encourag[ing]
new, smaller farming operations such as Community Supported Agriculture Farms.” The plan’s objectives include protection and preservation of agricultural land,
supporting purchase of local foods, and capitalizing “on the mutual benefi t of the connections between rural economies as producers of food and urban economies as processors and consumers.” The plan recommends mapping of agricultural operations located within the city, supporting education of farmers and consumers, and expansion of community gardens to ensure one garden per 2,000 households in the city. [4]
‘Blueprint Boise’ (Idaho), a proposed update of Boise’s comprehensive plan32, addresses food in a subsection on environmental stewardship. One goal within this subsection is to “promote community- based and local food production.” Recommended actions to reach this goal include designating public lands for community gardens, encouraging schools to create community gardens on school property, adopting zoning amendments that encourage food production, and allowing farmers’ markets as-a-right in designated activity centers. In addition, as part of a goal to “protect access to and promote use of the city’s canal system” the plan recommends that the city “require the use of existing water rights as new development occurs, particularly to support urban agriculture and community gardens.” [5]
References to the food system are interwoven throughout the 2005 update of the ‘City of Seattle Comprehensive Plan’ (Washington), which is intended to guide the city’s growth and development to 2024.
The plan makes several references to the provision of community gardens as both a goal and a strategy to reach other overarching goals. The plan identifi es a target standard of one community garden per 2,500 households in each designated “village” area throughout the city. [6]
County-scale comprehensive plans
The ‘2030 Harrison County Comprehensive Plan’ (Mississippi), adopted by the Harrison County Board of Supervisors and the citizens of Harrison County in 2008, addresses the food system in its section on healthy communities. The section aims to ensure that residents “live in healthy communities that have opportunities for active living, recreation, affordable healthy foods, and services for vulnerable populations.” One specifi c goal of the plan is to
“increase access to healthy food options in Harrison County.” The county proposes to achieve this goal by 3 Th e plan was recommended for approval to City Council on May 10, 2010. It is currently being reviewed by Council.
(1) developing a land bank of tax-reverted, vacant, and abandoned properties for agricultural uses, (2) promoting farmers markets, (3) promoting community gardens, and (4) improving local food accessibility. [7]
The section on “Agricultural, Natural and Cultural Resources” in the 2007 ‘Dane County Comprehensive Plan’ (Wisconsin) expresses a strong call “to conserve and effectively manage Dane County’s irreplaceable agricultural, natural and cultural resources, including … productive agricultural areas.”
The plan’s goals include protecting agricultural land, making farming economically viable, and maintaining the rural character of the county. Objectives include implementing fees to convert land from agricultural use to non-farm use, educating farmers about cost- saving measures, and encouraging compact future growth. The plan recommends continued support of the Dane County Food Council, revision of the county’s zoning and land division ordinances “to establish design guidelines that minimize conversion of agricultural land, and support farm operations and agriculture-related businesses,” and development of a viable and affordable option of health insurance for rural farmers. [8]
The award winning ‘Marin Countywide Plan’
(California), adopted by the County Board of Supervisors in 2007, includes a subsection on “Agriculture and Food” that includes three food-related goals: (1)
“preservation of agricultural lands and resources,” (2)
“improved agricultural viability,” and (3) “community food security.” The plan recommends that the county
* Limit permitted non-agricultural development within the Agricultural Production Zone to a “building envelope covering no more than 5% of the property.”
* Subject any proposed residential development above 4,000 square feet [located in agricultural areas] to design review.
* Limit single family residences to less than or equal to 7,000 square feet in agricultural areas.
Marin County Comprehensive Plan – Indicators and targets for strengthening the food system
Indicators Benchmarks Targets
Acres preserved with agricultural ease-
ments. 28,377 acres preserved
in 2000 Increase by 25,000 acres by 2010 and by 12,500 additional acres by 2015
Acres of land farmed organically 357 acres in 2000 Increase by 1,500% by 2010 and 1,700% by 2015
Annual sales of identifi ed Marin farmers’
markets: Civic Center, Downtown San Rafael, Novato, and Fairfax
$9,860,000 in 2005 Increase annual sales 10% by 2010 and 15% by 2015
* “Amend the Development Code to require space for on-site community gardens in [all] new residential developments of 10 units or greater.”
Regional-scale comprehensive plans
Adopted in 2008 by the Metropolitan Area Planning Council (MAPC), the ‘MetroFuture Plan’ aims
“to better the lives of the people who live and work in Metropolitan Boston (Massachusetts) between now and 2030” [10]. References to the food system exist throughout the plan but are explicit in a section on
“Community Vitality.” The plan envisions a healthy community and a healthy food system and outlines the following goals and objectives to achieve this vision:
The plan recommends that the legislature establish a Massachusetts Food Policy Council, the Massachusetts Offi ce of Small Business and Entrepreneurship assist healthy food stores with financing, and the M a s s a c h u s e t t s Avenue of Business Development to develop an “urban s u p e r m a r k e t
initiative.” The
plan also recommends the use of “school-based programs to help children establish healthy lifestyles” including improving school nutrition, creating “Edible Schoolyards,” and expanding farm-to-school programs.
Finally, the plan suggests reconnecting public health and planning issues by establishing “coordinating mechanisms between health and planning boards and agencies.” [12]
On the West Coast of the country, the ‘Regional Comprehensive Plan’ accepted by the Regional Council of the Southern California Association of Governments (SCAG) in 2008 addresses the food system within a section on “Agricultural Lands.” The main goal outlined in this section is to:
The plans calls for the enrollment of 6,500 acres of prime farmland in the region’s new conservation program within the fi rst four years and no net loss of farm acreage enrolled in the program through 2035.
[13
Preserve the productivity and viability of the region’s agricultural lands while supporting a sustainable economy and region by maintaining a viable level of agriculture to support economic and food supply needs for the region while supporting sustainable energy, air quality and transportation policies [and by] promot[ing] and support[ing] a strong locally-grown food system by encouraging community farming and developing cooperative farming initiates that use sustainable farming practices.
* All neighborhoods will have access to safe and well-maintained … community gardens
* Residents in all communities and of all incomes will have access to affordable, healthy food
* The region’s agricultural economy will grow
through a focus on sustainable farming and by bringing more locally produced food to the market [11]
The plan includes specifi c indicators, benchmarks, and targets to measure and evaluate progress towards goals (see example below). [9]
Environment, Sustainability, and Climate Change Plans
In recent years, local governments have begun to recognize that any efforts to improve the environment and tackle climate change must also address the food system. A growing number of environmental, sustainability, and climate change plans include entire sections devoted to building sustainable food systems as a strategy for improving the environment and addressing climate change (e.g.
Portland and Multnomah County, OR; Baltimore, MD;
Philadelphia, PA; Santa Fe, NM; Toronto, ON).
The ‘Climate Action Plan 2009,’ adopted by the city of Portland and Multnomah County (Oregon), provides a guide to future development in response to climate change, and includes a chapter on “Food and Agriculture.” The chapter discusses the impact of the food system on carbon emissions, and includes two food-related objectives to reduce the impact on climate change. The objectives are to: 1)
“reduce the consumption of carbon-intensive foods”
and 2) “signifi cantly increase the consumption of local food.” The plan recommends concrete actions to achieve these objectives before 2012, including partnering with schools to promote healthy low-carbon diets and the provision of incentives and removal of regulatory barriers to encourage local food production.
Measureable actions include promoting fruit and nut trees as part of a ‘Grey-to-Green’ tree-planting initiative to plant 33,000 trees in private yards as well as “develop[ing] or facilitat[ing] 1,000 new community garden plots.” [14]
‘The Baltimore Sustainability Plan’ (Maryland), approved by the Baltimore City Council in 2009, aims to “establish Baltimore as a leader in sustainable, local food systems.” Strategies to rebuild food systems appear in various sections of the plan; key strategies are noted below (chapters shown in parenthesis):
1. increas[ing] the percentage of land under cultivation for agricultural purposes (Greening)
2. improv[ing] the quantity and quality of food available at food outlets (Greening)
3. increase[ing] demand for locally-produced, healthy foods by schools, institutions, supermarkets, and citizens (Greening)
4. develop[ing] an urban agriculture plan (Greening) 5. implement[ing] Baltimore Food Policy Task Force recommendations related to sustainability and food (Greening)
6. compil[ing] local and regional data on various components of the food system (Greening)
7. compost[ing] residential yard and food waste and commercial food waste to the greatest extent (Resource Conservation). [15]
Released in 2009 by Philadelphia Mayor’s Offi ce of Sustainability, ’Greenworks Philadelphia’
(Pennsylvania), is a sustainability plan to make Philadelphia “the greenest city in America.” The plan considers sustainability through fi ve lenses: energy, environment, equity, economy, and engagement.
Two of these – environment and equity - address the food system. To reach its environmental goal of
“[diverting] 70 percent solid waste from landfi lls,” the plan’s environmental section encourages composting to reduce food waste. The equity section prioritizes food access by establishing a target to “bring local food within 10 minutes of 75 percent of” city residents.
Recommended actions to reach this goal include increasing access to fresh foods by creating 59 food producing gardens, 12 farms, and 15 farmers’ markets, creating an inventory of community gardens, urban farms, and farm stands, providing technical assistance to farmers/gardeners, leveraging vacant city-owned land for gardening purposes, fostering commercial
farming, encouraging distribution of healthy foods in neighborhood stores, and supporting food cooperative expansions. The plan also recommends enhancing entrepreneurial and workforce development opportunities such as “creat[ing] an agricultural workforce strategy to grow green jobs” and
“support[ing] green kitchen development.” [16]
The ‘Sustainable Santa Fe Plan’ (New Mexico), adopted by the City of Santa Fe in 2008 to reduce greenhouse gas emissions, includes a chapter dedicated to the food system. Although food-related initiatives to decrease “food miles” already exist in Santa Fe, the plan proposes three additional strategies.
1. To set a target for the percentage of consumed food to be grown locally; e.g., the plan proposes that the city establish a target such as 30% of the food consumed be from a 300-mile foodshed by 2018.
2. To design and implement a City Harvest program which provides multiple opportunities for growing, processing, storing, and selling food.
3. To “develop a foodshed (within 300 miles range) program in collaboration with regional partners.” This would include hiring a coordinator, expanding existing programs, preserving productive land, exploring food-related policies, and reducing transportation by coordinating a cooperative back-hauling43 program.
[17]
The ‘Change is in the Air: Climate Change, Clean Air and Sustainable Energy Action Plan,’ released by the city of Toronto’s Environment Offi ce and adopted by Toronto City Council in 2007 (Ontario), directs several recommendations to the food system. [18]
The plan recommends that the City establish a Live Green Toronto Program “to support residents’ groups, Business Improvement Areas and other neighbourhood agencies and community groups to green their own neighborhoods through a range of programs” such as planting food gardens at parks and homes. The plan also recommends new institutional mechanisms such as the creation of “an Enviro-Food Working Group to develop and implement actions to promote local food production, review City procurement policies, increase community gardens, and identify ways to remove barriers to the expansion of local markets that sell locally produced food.” [19]
4 Most trucks that deliver food products return to the distribution centers empty. Th is program would maximize the use of the trucks, ensuring they were loaded in both directions.
FOOD SYSTEM FOOD SYSTEM
PLANS PLANS
A small, but growing, number of local governments have created stand-alone, comprehensive, food system plans. These food system plans have been developed at varying scales, including neighborhoods (e.g. Buffalo, NY), municipalities (e.g. New York, NY;
Oakland, CA; Toronto, ON), counties (e.g. Dane County, WI; Multnomah, OR), and regions (e.g. Delaware Valley Region, PA; Waterloo, ON). They describe communities’
goals for their food systems, assess the conditions of food systems, and make recommendations for improving them.
A few communities have also developed plans for a specifi c component of the food system (i.e.
production, processing, distribution, etc.). Existing plans for a particular component of the food system tend to focus on food production (e.g. urban agriculture plans) rather than processing, distribution, or disposal.
Comprehensive Food System Plans
Neighborhood-Scale food system plan
In 2003 the Massachusetts Avenue Project, in collaboration with a graduate planning studio from the University at Buffalo (State University of New York), released ‘Food for Growth: A Community Food System Plan for Buffalo’s West Side.’ Focused on a specifi c neighborhood on the west side of Buffalo, New York, this plan assesses the neighborhood’s food security and the food system, and provides recommendations for improvement. Recommendations within four strategic areas include: (1) enhancing local food production through effective land use planning and by connecting consumers with Western New York farmers, (2) promoting food-based economic development, (3) improving transportation access to food, and (4) facilitating youth development through food-based projects. The plan has been since implemented by the Massachusetts Avenue Project. [20]
City-wide Food System Plans
In 2010 the New York City Council released
‘Food Works: A Vision to Improve NYC’s Food System,’ a comprehensive food system plan which outlines goals and strategies for production, processing, distribution, consumption, and post-consumption of food. Food production goals include preservation of and increase
in urban and regional food production. Strategies to meet these goals include “strengthen[ing] regional food supply channels, leverag[ing] the city’s economic power to support regional producers,” using existing space for urban food production more effectively, and “restor[ing] food and horticultural knowledge.” Food processing goals include generating growth and employment in the food manufacturing sector by making affordable space and technical assistance available to food manufacturers; to “increase regional products processed in and for New York City” by facilitating urban-rural linkages; and, to “reduce the environmental impact associated with food processing in New York City” by helping businesses reduce energy consumption. [21]
Food distribution goals include “improve[ing]
food distribution in New York City through infrastructure enhancements, technological advances, alternative
transportation, and integrated planning.” Strategies to reach this goal include “expand[ing] on the current vision for the Hunts Point Food Distribution Center to maximize its potential and diversify[ing] and improv[ing]
food transport.” [21]
Food consumption goals of the plan are to
“create a healthier food environment” by “expand[ing]
fresh food retail in underserved areas of the city,”
supporting “food outlets that provide fresh and healthy foods” better, and “discourag[ing] unhealthy food consumption.” The plan also aims to “strengthen the safety net of hunger and nutrition programs” through
“improv[ing] federal food programs and remov[ing]
local barriers to enrollment,” improve nutritional
quality of institutional meals by “expand[ing] the capacity of city agencies to cook whole foods for nutritious meals;” and, to “increase [the] quantity and quality of opportunities for food, nutrition, and cooking knowledge.” [21]
Post consumption goals included in the plan are to “decrease waste throughout the food system and increase resource recapture in the food system” by
“improv[ing] the net environmental impact associated with food procured by city agencies and institutions, increas[ing] residential, commercial, and governmental composting, and increas[ing] recycling of waste related to food processing and packaging.” [21]
Also in 2010, on the West Coast of the country, the Oakland Food Policy Council (California), an advisory group for the city, released ‘Transforming the Oakland Food System: A Plan for Action.’ Building on a previous food system assessment, the food policy council recommends that the city: (1) protect and expand urban agriculture, (2) encourage accessible and affordable farmers’ markets, (3) promote use of food assistance programs at farmers’ markets, (4) develop environmentally preferable purchasing protocols, (5) expand composting and food scrap recycling, (6) develop a fresh food fi nancing initiative, (7) encourage healthy mobile vending, (8) establish synthetic pesticide and GMO-production free zones, (9) scale up local purchasing, and (10) strengthen community-government links. [22]
The City of Toronto (Ontario), which has led the forefront of the food systems work in North America, is currently in the throes of preparing a food systems plan. The city’s Public Health Department is preparing a comprehensive food system plan as part of the Toronto Food Strategy project to create a health-focused food system. As a precursor to this plan, in 2010 the Public Health Department released
‘Cultivating Food Connections’ which proposes a vision for a healthy food system. The document describes
“numerous opportunities for Toronto to champion food system renewal” and “is the product of broad consultation with individuals and groups across City government and the community.” The fi ndings in this document will be used to inform the comprehensive food system plan which is scheduled for presentation to the Toronto Board of Health in May 2011. [23]
County-wide food system plan
The Multnomah County Offi ce of Sustainability (Oregon) released the ’Multnomah Food Action Plan:
Grow and Thrive 2025’ in December 2010. The plan aims to “achieve a local, healthy, equitable, and regionally prosperous food system” through “education, community empowerment, planning integration, policy prioritization, and investment.” The plan includes a call to action which includes 16 community-identifi ed goals, and 60 organization-based actions related to local food, healthy eating, social equity, and economic vitality. Selected indicators in the plan include increasing the number of full service grocery stores by 20%, increasing participation in the Supplemental and Nutrition Assistance Program (SNAP) by fi ve percentage points, reducing number of low-income households living farther than one mile from a grocery store by 20 percent, reducing fast food expenditures per capita by 10%, and reducing obesity rates among low-income preschool by three percentage points – all over a period of 15 years. [24]
In July 2005 the Dane County Local Food Policy Advisory Subcommittee (Wisconsin), appointed by the Environment, Agriculture and Natural Resources
committee of the Dane County Board, released ’Recipe for Success,’ a plan to improve the county’s food system. The plan makes calls for an effort to “buy fresh /buy local” through institutional purchasing policies51,
“establish[ing] a countywide network of farmers’
markets, support[ing] farm-to-school programs, and identify[ing] areas of need.” The plan recommends the completion of a needs assessment, organization of a stakeholder community, and the creation of a business plan for the development of a Public Market as well as a Central Agricultural and Food Facility. The plan also calls for the “promot[ion] of farmland preservation and entrepreneurial agriculture” by adhering to the county’s comprehensive plan, promoting “small acreage farming zones, support[ing] entrepreneurial agriculture, and support[ing] local farmland preservation initiatives.”
The plan recommends improving access to local foods
“to improve health and nutrition,” collaborating with anti-hunger advocates to establish a “Market Basket” program, supporting and enhancing an existing Dane County Extension Nutrition Education Program, devoting county-owned land for community gardens, encouraging direct marketing, CSA farms, farm stands, and U-Pick operations, and networking with existing Dane County Health and Nutrition projects. The plan also recommends the establishment of a Dane County Food Council, which has since been established. [25]
Regional-scale food system plan
Regional food system plans provide a promising opportunity to strengthen urban and rural linkages within a food system. Based on an extensive food system study [26], ’Eating Here: Greater Philadelphia’s Food System Plan,’ published in February 2011 by the Delaware Valley Regional Planning Commission, aims to increase “the security and economic, social, and environmental benefi ts of the regional food system that feeds Greater Philadelphia.” The plan’s ultimate goal is to create “a food system in which agriculture is a valued and economically viable occupation, natural resources are preserved and regenerated, healthy food is accessible and affordable, and diversity exists throughout the region.” The plan makes 52 recommendations to achieve this goal (although implementing actors are purposely not identifi ed). [27]
5 Specifi c recommendation - Th e County should set a goal that 10% of its food-related purchases should be made locally within three years
Key recommendations include:
1. Addressing the retirement needs of farmers, transitioning preserved land into food production, and creating investment vehicles for long-term agricultural production on preserved land
2. Development of technical assistance programs or market-based solutions that enable farmers to protect natural resources
3. Creation and expansion of programs to reduce barriers to entry for new farmers and food entrepreneurs 4. Integration of Farm-to-School programs into a robust and comprehensive education program
5. Continual convening of the Greater Philadelphia Food System Stakeholder Committee [27]
In April 2007 the Region of Waterloo (Ontario) Public Health Department released ‘A Healthy Community Food System Plan.’ Building on a study completed in 2005, this plan provides objectives, strategies, and actions to improve the region of Waterloo’s food system. The seven main objectives are to: (1) “ensure all residents can afford to buy the food they need to sustain health,” (2) “preserve and protect Waterloo Region’s agricultural lands,” (3) “strengthen food-related knowledge and skills among consumers,”
(4) “increase the availability of healthy food so that the healthy choices are easier to make,” (5) “increase the viability of farms that sell food to local markets in order to preserve rural communities and culture,”
(6) “strengthen the local food economy,” and (7)
“forge a dynamic partnership to implement the plan.”
Strategies include “increas[ing] urban agriculture, expand[ing] local farmers’ markets, encourag[ing] local food processing.”
Plans for a Component of the Food System Plans for a Component of the Food System
When resources for preparing a comprehensive food system plan are limited, local governments may prepare and adopt plans focusing on a particular component of the food system such as production, processing, distribution, consumption, or disposal of food. These plans typically establish goals for improving a particular component, assess the conditions in this component of the food system, and provide recommendations for improvement. Current component-specifi c plans for the food system tend
to focus on food production (e.g. Minneapolis, MN;
Madison, WI).
A recent example of a plan that focuses on the production component of the food system is an ’Urban Agriculture Policy Plan: A Land Use and Development Plan for a Healthy, Sustainable Local Food System’
adopted in April 2011 by the Minneapolis City Council (Minnesota) to promote urban agriculture. The plan’s recommendations include altering the existing zoning code to defi ne and permit urban agriculture related activities, incorporating urban agriculture into the city’s long range planning efforts, and reviewing the City’s land inventory to fi nd opportunities for urban agriculture. The plan also includes an assessment of land demand for urban agriculture. [29] Our research suggests that this is possibly the fi rst offi cially adopted urban agriculture plan in the United States.
About a decade earlier, in 1999, the City of Madison Advisory Committee on Community Gardens adopted ‘Growing a Stronger Community with Community Gardens,’ a community gardens plan for the City of Madison, Wisconsin. The plan describes the state of community gardens as well as strategies and tools for preserving existing and creating new gardens.
The plan recommends fi ve policies. It recommends (1) extension of the lease period for community gardens on city-owned lands to a minimum of fi ve years. The plan calls for (2) “community gardens [to] be developed as permanent public assets” with fi nancial support from the city government, as well as (3) “through planning and zoning actions.” Because community gardens require continual institutional and organizational support, the plan recommends (4) the establishment of a Community Gardens Council and the hiring of a coordinator. The plan calls for (5) a partnership among city government, community
Offi cial plans that include references to the food system
Comprehensive or General Plans
Municipal-scale
Dillingham, AK Adopted in 2011 by the City Council
* The City of Dillingham Comprehensive Plan Update and Waterfront Plan addresses food- related goals, strategies, implementation timeline, and responsible entity within the energy section of the plan
New Orleans, LA Adopted in 2010 by the City Planning Commission
* The New Orleans 2030: Plan for the 21st Century has a subsection on urban agriculture , gardening, and open space including current conditions, goals, and recommended actions
Madison, WI Adopted in 2006 by the Common Council Released by the Department of Planning
* The City of Madison Comprehensive Plan has a chapter dedicated to natural and agricultural resources including goals, objectives, and policies to encourage the preservation and growth of both rural and urban farms.
* Specifi c target to create one community garden site for every 2,000 city households Boise, ID
Recommended for city council approval in 2010 by the Planning and Zoning Commission
* Blueprint Boise, the city’s comprehensive plan, includes goals to promote community-
based and local food production in a subsection on environmental stewardship
* Recommended actions are discussed to reach these goals such as designating public lands for community gardens
Seattle, WA Adopted in 2005 by the City Released by the Dept. of Planning and Dev.
* References to community gardens are interwoven through the City of Seattle Comprehensive Plan
* The plan recommends an increase in number of gardens city-wide as well as a target of one community garden for each 2,500 households located within designated villages throughout the city
County -scale
Harrison County, MS Adopted in 2008 by the Board of Supervisors
* The 2030 Harrison County Comprehensive Plan addresses food in a section dedicated to public health including goals, strategies, and actions to increase access to healthy food options
Dane County, WI Adopted in 2007 by the Board of Supervisors Released by the Department of Planning
* The Dane County Comprehensive Plan addresses the food system in a chapter dedicated to agricultural, natural, and cultural resources
Marin County, CA Adopted in 2007 by the Board of Supervisors Released by the Community Dev. Agency
* The Marin Countywide Plan has a chapter dedicated to natural systems and agriculture elements including a subsection on agriculture and food which considers current conditions, key trends, and issues to create goals, policies, and implementation strategies
PLANS TO SUPPORT HEALTHY PLANS TO SUPPORT HEALTHY
FOOD SYSTEMS
FOOD SYSTEMS
Regional-scale
Boston Metro Region Adopted in 2008 by the Metropolitan Area Planning Council
* The MetroFuture Plan references the food system in its vision, goals, objectives, indicators, strategies, and recommended actions within the community vitality section
Southern CA Accepted in 2008 by the Assn. of Governments
* The 2008 Regional Comprehensive Plan has a subsection on agricultural lands including current conditions, eating locally and sustainably, goals, and outcomes
Environment and Climate Change Plans
Municipal-scale
City of Portland and Multnomah County, OR Adopted in 2009 by the City Council and the County Board of Commissions
* The Climate Action Plan 2009 includes subsections on reducing consumption of carbon- intensive foods, increasing consumption of local foods, and reducing and recovering food and solid waste with accompanying objectives and actions to be completed before 2012
Baltimore, MD Approved in 2009 by the City Council
* The Baltimore Sustainability Plan describes goal and strategies for building sustainable, local food systems in its section on Greening
* Also addresses food in a chapter devoted to Resource Conservation, which outlines a goal to minimize waste by composting food waste
Philadelphia, PA Released in 2009 by the Mayor’s Offi ce of Sustainability
* Greenworks Philadelphia includes targets and strategies to bring local food within 10 minutes of 75 percent of all city residents in a section dedicated to equity
* Also includes including a target to divert 70 percent of solid waste from landfi lls in a section dedicated to the environment
Santa Fe, NM Adopted in 2008 by the City Released by the Sustainable Santa Fe Commission
* The Sustainable Santa Fe Plan includes subsections on solid waste reduction and food systems with accompanying proposed actions
Toronto, ON Adopted in 2007 by the City Council Released by the Toronto Environment Offi ce
* The Climate Change, Clean Air and Sustainable Energy Action Plan recommends the creation of the Live Green Toronto Program, one activity of which is to promote home and community gardening projects. The plan also establishes the inter-divisional Enviro- Food Working Group to promote local food production, “review City procurement policies, increase community gardens, and identify ways to remove barriers to the expansion of local markets that sell locally produced food.”
Food System Plans Comprehensive Food System Plans
Neighborhood-scale
Buffalo, NY West Side Released in 2003 by the University at Buffalo – Department of Urban and Regional Planning and Massachusetts Avenue Project
* Food for Growth: A Community Food System Plan for Buffalo’s West Side assesses food security including demographics, community
perspectives, trends in hunger, and affordability and quality of food
* Recommends strengthening the community food system by enhancing local food production through land use planning, promoting food-based economic development, improving transportation access to food, and promoting West Side youth development through food-based projects
* Provides recommendations and identifi es responsible implementing agency
Municipal-scale
New York, NY Released in 2010 by the New York City Council
* Food Works: A Vision to Improve NYC’s Food System explores food system trends over time
* Considers moving from food system insecurity to opportunity
* Describes current conditions, goals, strategies, and proposals for food production, processing, distribution, consumption, and post consumption
Oakland, CA Released in 2010 by the Oakland Food Policy Council
* Transforming the Oakland Food System: A Plan for Action provides goals for improving the Oakland food system and reports on trends and current conditions within the Oakland food system
Toronto, ON Released in 2010 by the Department of Public Health
* Cultivating Food Connections proposes a vision of a healthy food system, discusses the city’s numerous opportunities, and documents the suggestions and opinions of both
government and public stakeholders in the food system
* This study is being used to inform the creation of a comprehensive food system plan
County-scale
Multnomah
County, OR Released in 2010 by the Multnomah County Offi ce of Sustainability
* The Multnomah Food Action Plan: Grow and Thrive 2025 outlines 16 goals to promote Local Food, Healthy Eating, Social Equity, and Economic Vitality
* Provides specifi c indicators for each goal to track progress - includes current conditions and benchmarks for 2018 and 2025
Dane County, WI Released in 2005 by the Dane County Local Food Policy Advisory Subcommittee
* Recipe for Success outlines recommendations with suggested actions and next steps
* Examines several topics including - Buy fresh / buy local; a central agricultural and food facility and public market; farmland preservation and entrepreneurial agriculture; local foods to improve health and nutrition; establish a Dane County food council
Regional-scale
Delaware Valley Released in 2011 by the Delaware Valley Regional Planning Commission
* Eating Here: Greater Philadelphia’s Food System Plan outlines six core values and one ultimate goal
* 52 recommendations are discussed and indicators are documented to measure progress
Waterloo, ON Prepared in 2007 by the Region of Waterloo Public Health Dept.
* A Healthy Community Food System Plan addresses key informant consultation process
* Announces objectives, strategies, and actions resulting from focus group
* Discusses current progress on actions and further recommendations
Plans for a component of the food system
Municipal-scale
Minneapolis, MN Adopted in 2011 by the City Council
* The Urban Agriculture Policy Plan: A Land Use and Development Plan for a Healthy,
Sustainable Local Food System examines existing urban agriculture policies and facilities
* Outlines issues and opportunities and presents recommendations Madison, WI
Adopted in 1999 by the City of Madison Advisory Committee on Community Gardens
* Growing a Stronger Community with Community Gardens analyzes the current state of community gardens in the city of Madison
* Considers location of community gardens including neighborhood characteristics
* Suggests strategies and tools for preserving existing and creating new community gardens
* Sets action plan recommendations
REGULATORY REGULATORY TOOLS
TOOLS
gardening organizations and individual gardeners.
Several recommendations of this plan were ultimately incorporated in the city’s comprehensive plan and have since been implemented. [30]
Local government regulations play a signifi cant role in facilitating or hindering a healthy food system through permitting (or, prohibiting), licensing, monitoring, or otherwise regulating food-related activities in a community. For example, a zoning code that prohibits mobile vending of fresh produce but permits hotdog vending in residential districts makes it relatively harder for residents to purchase healthy foods in their neighborhoods. Fortunately, local governments are using a variety of regulatory tools to support production, processing, distribution, and consumption of healthful foods as well as to support sustainable forms of food waste disposal.
These regulations include modifying zoning ordinances to recognize urban agriculture62 as a permitted use in cities to ordinances that permit farm animals and bees in urban areas.
FOOD PRODUCTION FOOD PRODUCTION
Supporting crop production through zoning and other regulations
A growing number of municipalities around the country are modifying zoning ordinances to permit and support food production. Community gardening, large-scale farming, green houses, truck gardens and other type of crop production are a permitted land use in multiple zoning districts in several cities. In Kansas City, MO, community gardens, defi ned as “an area of land managed and maintained by a group of individuals to grow and harvest food and/or horticultural products for personal or group consumption or for sale or donation,” are permitted in all residential zones although sale and donation of produce is restricted 6 See the American Planning Association’s
Planning Advisory Service Report Number 563 for a detailed analysis of regulatory tools relating to urban agriculture. [1]
to particular residential zones (discussed further in food retail/distribution section). This recognition is the result of recent modifi cations to the zoning code (June 2010). [31]
San Francisco, California’s Planning Code recognizes multiple forms of food production including community gardens, neighborhood gardens, greenhouses, plant nurseries, and truck gardens.
Community gardens and neighborhood gardens are permitted as a principal use in all residential districts provided the open space is “used for horticulture or passive recreational purposes which is not publically owned and is not screened from public view, has no structures other than those necessary and incidental to the open land use, is not served by vehicles other than normal maintenance equipment, and has no retail or wholesale sales on the premises.” Green houses, plant nurseries, and truck gardens are permitted as a principal use in most commercial and manufacturing districts, and are “subject to approval by the City Planning Commission as a conditional use” in all residential districts. [32]
Other cities allow large scale farming as a permitted use within particular zoning districts (e.g. New Orleans, LA; Austin, TX). New Orleans, Louisiana’s Comprehensive Zoning Ordinances permits farms on sites of at least fi ve acres and private and truck gardens (without sale on-site) as-a-right in all residential and commercial zoning districts. [33] The City Code of Austin, Texas permits farms of one to fi ve acres in most zoning districts and allows agricultural products raised on these farms to be sold from the site, subject to some regulations. [34]
Still other cities permit agricultural uses within their development and form based codes (e.g.
Forsyth, GA; Denmark Township, MN; Mint Hill, NC;
Hutto, TX). Forsyth, Georgia’s Zoning Ordinance permits non-commercial gardens as an accessory use to single-family detached dwellings located within traditional neighborhood development districts. [35]
Denmark Township, Minnesota’s Development Code permits agriculture (including demonstration farms), community gardens, and composting (for waste generated by residents of the development) as open space uses within open space design subdivisions.
[36]
Some cities are currently in the process of changing their zoning codes to further support food production. For example, San Francisco, California’s Mayor and President of the Board of Supervisors introduced an ordinance (December 14, 2010) which will facilitate the local production and sale of fresh produce throughout all zoning districts. This ordinance will defi ne and recognize “neighborhood agriculture” and “large scale urban agriculture” as permitted uses, either by right or with conditional use authorization.
Proposed language defi nes neighborhood agriculture as less than one acre and allows the use in all zoning districts while large scale urban agriculture is greater than one acre and requires conditional use authorization in most zoning districts (including residential). The ordinance will allow the limited sale of produce on otherwise vacant property. On February 17, 2011 the city’s Planning Department recommended approval of the ordinance with modifi cation to the Board of Supervisors. These modifi cations include clarifying the language that allows produce grown on site to be sold on site and adjusting the compost setback requirements. [37]
Boston, Massachusetts’ Zoning Code and Enabling Act establishes nine categories of sub- districts, including a “Community Garden Open Space Sub-district,” within an open space zoning district.
The Community Garden Open Space Sub-district
“shall consist of land appropriate for and limited to the cultivation of herbs, fruits, fl owers, or vegetables, including the cultivation and tillage of soil and the production, cultivation, growing, and harvesting of any agricultural, fl oricultural, or horticultural commodity;
such land may include Vacant Public Land.” [38]
Permitting Food Production in Overlay Districts
A fl exible option for improving the food environment through zoning ordinances is through the use of an “overlay district.” An overlay district can include healthy land uses – such as urban agriculture – that would otherwise not be permitted in a particular zoning district.
Community gardens are listed as a permitted open space type within the Downtown Overlay A (DO- A) Neighborhood District in the Downtown Mint Hill Overlay Code of Mint Hill, North Carolina. Properties must follow general building design guidelines and architectural requirements. For example, all garden walls are required to be “made of brick, stone, or
stucco matching the principal building.” [39]
In Cleveland, Ohio a special “Urban Garden Overlay District” is pending adoption by the city council. The district is designed to:
(a) provide appropriately located and sized land for urban agriculture use;
(b) facilitate local food production and improve community health;
(c) provide local opportunities for agriculture-based entrepreneurship and employment;
(d) enhance the environment and improve stormwater management;
(e) ensure safe and sanitary conditions for urban agriculture uses;
(f) to protect nearby residential areas from any adverse impacts of agricultural use; and
(g) to ensure that land best suited for non-agricultural use remains available for such use.
Cleveland’s overlay district will permit the raising of livestock more intensively than in other zoning districts.
[40]
Seattle, Washington’s Department of Transportation allows residents to plant food in the planting strip immediately abutting their residence.
Certain setback and height requirements must be followed as outlined in “The Seattle Right-of-Way Improvements Manual.” Additionally, most fruit trees are prohibited as falling fruit poses a threat to pedestrians. As of 2009, street use permits and their accompanying fees are not required for gardening activities; however, a free street use permit is required for planting trees or installing hardscape elements such as raised planting boxes. [41]
Incentivizing Food Production in Planned Unit Developments
Some cities provide incentives for including urban agriculture within planned neighborhoods (e.g.
Minneapolis, MN Milford, DE). Minneapolis, Minnesota’s zoning code provides incentives for promoting food production in “planned unit developments” (PUD). As PUDs are built on large sites, the code provides “for
fl exibility in the use of land and the placement and size of buildings in order to better utilize the special features” of the sites. This fl exibility requires the developer to provide a tradeoff: PUDs must include 10 points worth of pre-approved special amenities which ultimately result in higher quality developments.73 Also, for each approved alternative to the zoning regulation, PUDs must include an additional fi ve points of special amenities. As an incentive to promote food production, developers can gain 10 points for incorporating green roofs, fi ve points for including gardens or on-site food production capability, and three points for integrating living wall systems. [42] Milford, Delaware’s Code of Ordinances awards a 5% density bonus to Planned Residential Neighborhood Development projects that reserve additional common land for community gardens. [43]
Permitting Food Production through Form-based Codes
A form-based code adopted in 2009 by the City of Hutto, Texas explicitly supports food production.
The land area in this ‘SmartCode’ is broken into six transect zones – Natural, Rural, Sub-Urban, General Urban, Urban Center, and Urban Core. The code permits various forms of food production –by right or by warrant - within all zones (see below). Unless specifi ed otherwise, all food production shown in each transect is permitted “by right.” [44]
Natural zone: Green roofs; Vegetable plots (by warrant); Farms (by warrant)
Rural zone: Green roofs; Vegetable gardens;
Community gardens; Agricultural plots; Farms
Sub-Urban zone: Green roofs; Vegetable gardens;
Agricultural plots; Urban Farms; Community Gardens General Urban: Green roofs; Vegetable gardens; Urban Farms; Community Gardens
Urban Center: Green roofs; Urban Farms; Community Gardens; Vertical axis gardening
Urban Core: Green roofs
Favorable vacant land disposition policies
Public land disposition policies can also support food production by making public land available for community gardening and urban agriculture. A Real 7 Th e zoning code provides a table of amenities that are assigned a certain number of points and specifi c standards to be met.
Estate Disposition Policy adopted by the city council of Minneapolis, Minnesota in 2004 allows excess city-owned vacant non-buildable lots in the city’s land inventory to be purchased by a nonprofi t corporation or public agency to use as a community garden for enjoyable, recreational, and sustainable purposes for city residents. The purchaser must place a conservation easement on the community garden lot in favor of the city. Accessory buildings may be constructed for tools, equipment, and storage as permitted by the Building and Zoning Codes. [45]
Still other cities have city programs and policies for allowing the interim use of public land for urban agriculture (e.g. Hartford, CT; Utica, NY; Rochester, NY). Many cities create garden programs or charge a specifi c city department with the task of issuing garden permits for vacant city-owned land. Hartford, Connecticut’s Parks and Recreation Advisory Commission administers a municipal gardening program “to encourage the use of vacant public land owned by the City for gardening purposes by the general public.” [46] Utica, New York’s commissioner of urban and economic development manages the Utica Community Garden Program which “negotiate[s]
and enter[s] into contracts with interested community organizations for the purpose of establishing community gardens on vacant city-owned land.” [47]
Rochester, New York charges the Director of Real Estate to issue garden permits “for use of City-owned vacant lots by the public, for gardening purposes.” [48]
Ordinances permitting agricultural livestock – chickens, bees, and goats - in cities
A number of local government ordinances permit the raising of farm animals and bees in urban
areas. These ordinances regulate the type and density of animals (based on square footage of lot or per lot), setback requirements for facilities raising animals, licensing requirements, and require the owners to follow strict sanitation codes.
Fowl
Many cities, including Buffalo, New York, allow fowl to be raised and kept in particular zoning districts.
In Madison, Wisconsin the zoning ordinance allows the
“keeping of up to four (4) chickens on a [residential]
lot” provided the owner obtains a license ($10.00/
year) and follows the enclosure and setback rules stipulated in the ordinance. [49]
In Rochester, New York, up to thirty fowl may be kept in an open area of 240 square feet and each fowl must have at least four square feet of fl oor space when kept in a coop. Male fowl over the age of 4 months are prohibited after due notice by the Chief of Police that they are a nuisance. A license ($37.00/
year) is required to keep fowl. [50]
Land area requirements for keeping fowl and other animals can vary by zoning districts. In Cleveland, Ohio, for example, the space requirements for animals is higher in residential districts as compared to non- residential district and the proposed Urban Garden Overlay (UGO) district despite nearly identical setback and enclosure regulations in all districts. Residential lots are allowed to have one chicken, duck or similar small animal per 800 square feet while nonresidential parcels may have one per 400 square feet and the proposed UGO parcels may have one per 100 square feet. One rooster, goose, or turkey may be kept on both residential and nonresidential parcels of at least 1 acre with an additional one bird allowed per 24,000 square feet in excess of the one acre. The proposed UGO parcels may have one rooster per 10,000 square feet. A license must be obtained to keep any of the above animals. [40, 51]
In Seattle, Washington, where fowl are permitted in all zoning districts as an accessory use, eight fowl are allowed per lot; however, roosters are not allowed. A community garden or urban farm greater than 10,000 square feet may keep one additional fowl per 1,000 square feet in excess of 10,000 square feet.
[52]
Mountain View, California’s Code of Ordinances allows up to four hens without a permit if their enclosure is more than 25 feet away from neighboring residences. [53]
Small, medium, and large sized animals
Some cities permit raising livestock, including cows, goats, and sheep, within city limits. In Cleveland, Ohio, residential parcels may have one goat, pig, sheep, or other similar medium sized animal per 24,000 square feet with a maximum limit of two such animals if the parcel is larger than 26,400 square feet while nonresidential parcels may have one per 14,400 square feet with a maximum limit of two if the parcel is larger than 15,600 square feet. Parcels within the proposed Urban Garden Overlay (UGO) District may have one medium-sized animal per 4,000 square feet with no limit on maximum number. The proposed UGO parcels are also the only parcels which may have large- sized animals such as horses, cows, alpacas, llamas and similar farm animals (one per 8,000 square feet).
A license must be obtained to keep any of the above animals. [40, 51]
Similarly, in Rochester, New York one cow may be kept per standard city lot of 4,950 square feet (up to 15 cows per acre); however, “[e]ach cow must have at least 2,500 square feet of clear space in which to
exercise.” All other animals (beside cows and fowl) must “have at least one square foot of space for each pound in weight, if confi ned within a building, and in addition thereto at least one square foot of space for each pound of weight” in which to exercise. A license ($37.00/year) is required to keep farm animals. [50]
Seattle, Washington permits small animals as an accessory use in all zoning districts with some stipulations. In single-family residential zones “up to four small animals are permitted on lots of at least 20,000 square feet [with] one additional small animal permitted for each 5,000 square feet of lot area in excess of 20,000 square feet.” Miniature potbelly pigs are considered a small animal and must be shorter than 22 inches high and less than 150 pounds.
Additionally, miniature goats are considered a small animal provided they are neutered and dehorned. One cow, horse, sheep, or other similar animal may be kept in any zoning district per 10,000 square feet; however, they are only to be kept on lots of at least 20,000 square feet. Licenses are only required for miniature goats ($20.00/year) and potbelly pigs (New $120.00;
Renew $30.00/year). [52]
Beehives
Beehives, an essential component of the food system, are also permitted through municipal regulations. These regulations stipulate the number of hives per area, require licenses, and may require approval of adjacent property owners. For example, Cleveland, Ohio, permits one beehive per 2,400 square feet on residential parcels while nonresidential and the proposed UGO parcels may have one beehive per 1,000 square feet. [40, 51]
In Minneapolis, Minnesota, lots in any zoning district less than one-half (1/2) acre may have two colonies of bees. Lots between one-half (1/2) and three-quarter (3/4) acre may have four colonies. Lots between three-quarter (3/4) and one (1) acre may have 6 colonies. Lots between one (1) and fi ve (5) acres may have eight colonies. Finally, lots larger than fi ve (5) acres may have as many colonies “as determined by the manager of Minneapolis Animal Care and Control.”
A permit is required to have beehives (New $100.00;
Renew $50.00/year). To obtain a permit, applicants must receive written consent from at least 80% of neighbors within 100 feet of the property and 100%
consent from neighbors adjacent to the property. If the proposed location of the hive(s) is on a property greater than 4 acres, applicants must receive written
consent from at least 80% of neighbors within 250 feet of the hive(s) and 100% consent from neighbors within 150 feet of the hive(s). [54]
Seattle, Washington permits beehives as an accessory use in all zoning districts. No more than four beehives are allowed on lots of less than 10,000 square feet. [52]
FOOD PROCESSING FOOD PROCESSING
Zoning ordinances can also include
“designated zoning districts” to facilitate agricultural processing, manufacturing, and distribution. For example, Burlington, Vermont’s Code of Ordinances creates the Agricultural Processing and Energy (E- AE) District “to accommodate enterprises engaged in the manufacturing, processing, and distribution of agricultural goods and products, and those related to the generation of energy from renewable sources.”
Permitted uses in this district include agricultural uses, bakery retail and wholesale, community gardens, open air markets, warehouses, and wholesale sales. Cafés, food processing, small grocery stores (<10,000 SF), micro-breweries/wineries, recycling centers, solid waste facilities, and retail warehouses are conditional uses in this district. [55] Adopting zoning and other regulatory tools to support local and healthy food processing has the dual advantage of strengthening food systems and promoting economic development.
FOOD RETAIL FOOD RETAIL
Home gardens, community gardens, and farms
Many cities permit the sale of produce grown on home gardens, community gardens, and farms within residential and other zoning districts. For example, Kansas City, Missouri’s zoning code allows the on-site sale of food and/or horticultural produce grown in residential zoning districts. Sale is allowed either by-right or with a special use permit depending on whether the food production occurs on a home garden, community garden, or community supported agriculture farm. Whole, uncut, fresh food and/or horticultural products grown on home gardens, which are defi ned as “a garden maintained by one or more individuals who reside in a dwelling unit located on the subject property,” may be donated or sold on-site in all residential districts within a reasonable time of its harvest. The sale may take place only between May 15 and October 15. Home gardens in residential zones whose produce is sold or donated are not allowed to
